D'Arcy Gue

The Road to ICD-10: Our Latest, Riskiest Juncture

June 5, 2015

ICD-10 7 Minute Read

It seems senseless when good news is perceived as the opposite. But that is what is happening in some quarters of the healthcare industry. In this case, “senseless” may also be translated as “dangerous.”

On June 3rd, large healthcare providers and payers welcomed CMS’ report on its latest, successful round of end-to-end ICD-10 testing. They did so because most have spent years and millions of dollars preparing to convert from ICD-9 coding to the world standard of ICD-10 by this year’s deadline of October 1. They want to get on with it.

But, a positive CMS ICD-10 testing report is not good news to many providers that still want ICD-10 to go away. More importantly, the fact that they are still not on board with ICD-10 is becoming a huge problem for the entire healthcare industry.

Many, if not most, smaller providers, including physician practices and smaller hospitals, still have done little to implement ICD-10. On March 31, the Workgroup for Electronic Data Interchange (WEDI) reported that 50% to 75% of smaller providers are unlikely to be ready for ICD-10 by October 1, judging from their progress on preparatory steps like systems testing and business process changes. On the other hand, the large hospital organizations represented in the sample of nearly 800 providers expected to be ready, and had already completed most necessary preparations. Another survey, conducted in April by NueMD with 1000 providers, mostly small physician offices, reported that only 13% of respondents said they are “highly confident” they will be ready by October 1.

Many small providers continue to hope – and some still believe – that they will be rescued by another ICD-10 deadline delay. We all know that two delays have occurred in the last two years. Why not another?

This obstinate stance is risky at best, but continues to be fueled by various industry efforts to provide just such a rescue. The American Medical Association, nearly 100 other physician groups, and the Medical Group Management Association are still fanning the “no-ICD-10” fire. At this late date they are promoting efforts by a few congressmen to slow down or even kill national adoption of ICD-10. Ironically, at the same time, the AMA and MGMA are also providing ICD-10 workshops and guidance tools to support their memberships’ implementation efforts.

According to Steven Stack, the new president of the AMA: “ICD-10 should not only be delayed, but scrapped.” The AMA is putting its full support behind a bill recently introduced by Texas Republican Rep. Ted Poe, which would do just that. Two weeks ago,  Rob Tennant, MGMA’s HIT Policy Director, told me during the WEDI National Conference:  “The ICD-10 idea is a mess…and should not go forward.” He suggested that physicians’ practices will be hampered by ICD-10. He also was very skeptical of CMS’ end-to-end testing program, and believes the “scope of the testing” is superficial — that using only 875 testing entities across the nation’s entire provider population is an insufficient  sample. Tennant’s views were shared by other attendees, some going as far as claiming that they do not believe CMS’ testing reports. They cited issues such as sample size and their belief that “the industry is being given too few details” about the tests.

transition to icd-10Let’s put the record straight on CMS’ testing, its increasing significance, and why it just may be the straw that breaks the ICD-10 opposition’s back.

  • This week’s ICD-10 testing report was the second of three different CMS end-to-end testing periods. In late January, CMS conducted its first such testing round, with a test group of 661 providers submitting nearly 15,000 test claims. CMS’ systems accepted 81% of the claims. The test session was largely considered successful because submission errors unrelated to ICD-10 accounted for most of the reasons for non-acceptance.
  • CMS’ report this week covered a new testing round that CMS conducted in April. Approximately 875 providers participated, with over 23,000 test submissions, representing a substantially larger sample than the January test. The results – an 88% claims acceptance rate — significantly exceeded the 81% rate in the January round. According to CMS, the majority of claims rejections in the April round, once again, were due to errors unrelated to ICD-9 or ICD-10, such as use of incorrect National Provider Identifiers, insurance claim numbers or submitter IDs, or invalid dates of service. Invalid submissions of ICD-10 diagnosis or procedure codes accounted for 2% of claims rejections, and less than 1% of claims were rejected due to invalid submissions of ICD-9 code.
  • One more end-to-end testing week in July remains on CMS’ agenda. CMS expects that a sample of 850 providers will participate – approximately the same size as in the second test.  ICD-10 experts generally anticipate an even stronger set of results from the third test, as providers continue to weave their way through non-ICD-10 related issues that have impeded systems acceptance. CMS is conducting tester education to help participants avoid common testing environment errors.
  • CMS also has conducted acknowledgement testing several times. The most recent acknowledgement testing period in early March proved successful: 775 submitters submitted almost 9,000 claims, of which nearly 92% were accepted. Normally, fee for service (FFS) Medicare claims acceptance rates average 95-98 percent. Another acknowledgement testing round was conducted this week (June 1 – 4), and we should expect those results soon.

Shooting bullets at CMS for potentially insufficient preparation has been a favorite tactic of organizations opposing the transition to ICD-10. Indeed, a year ago, CMS had conducted only acknowledgement testing — not end-to-end testing. Now that it has diligently responded and achieved strong, successive end-to-end testing results, arguments against CMS systems’ ability to handle the transition appear frivolous.

Less than four months away from the ICD-10 deadline, providers that hold on to these arguments and continue to hope for another respite from ICD-10 are being unrealistic and putting the viability of their organizations at great risk. Simultaneously, they are putting the operations of their healthcare partners, e.g. the hospitals that they work with, at risk because they will not be able to collaborate in ICD-10-based healthcare communications such as orders and authorizations. This may very well jeopardize patient care.

CMS and private payers have been clear in stating that they will reject ICD-9 claims beginning October 1. Despite the islands of remaining opposition, there seems to be broad acceptance throughout the healthcare industry that ICD-10 will not be delayed again. There are several reasons:

  • The last deadline delay essentially stopped many organizations’  ICD-10 preparations, rather than facilitating a methodical transition through the benefit of extra time. Another deadline delay is unlikely to be different.
  • In the meantime, both CMS and most payers have done expensive end-to-end testing. Like CMS, private payers are intent on making ICD-10 happen on October 1.
  • Large hospital organizations, overall, are ready for ICD-10, and have found the delays very costly, requiring re-work.  They do not want another wait either.
  • Waiting to implement ICD-11 is not an option; it is not expected to be ready for actual application for several years. In the meantime,  U.S. healthcare will get further and further behind the rest of the developed world.
  • And, just four months from the October 1 implementation deadline, Congress continues to show no interest in changing it.

Small providers still have time. They can accomplish enough to be able to transmit ICD-10 based claims on October 1 and get them paid. This includes smaller hospitals, especially if they, at least, have completed an ICD-10 assessment. These providers may need to take short cuts in training, documentation, and process-related changes that are not ideal. However, if they quickly put the right people to work on the key elements of implementation, they can catch up on these issues over time. They also should work on revenue cycle contingency plans, to help offset cash impacts of claims payment delays.

You’ve read it before, I know. Act on ICD-10, if you haven’t already done so.

Your organization must be paid to continue its mission of patient care, and it won’t be paid if your claims are submitted without ICD-10 coding after October 1. Further, your organization must be able to communicate accurately and meaningfully with your healthcare partners, to coordinate patient care.  It won’t be able to, after October 1, if it isn’t speaking ICD-10.

We are just four months away from this industry-changing deadline. Act on ICD-10.


Our blog posts are intended to be a service to the healthcare industry. They are not advertisements. However, if you would like to discuss ICD-10 further, you are welcome to  contact us. I will make sure that a Phoenix ICD-10 specialist is on the phone to answer your questions within 24 hours.

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